SUBJECT: 29 CFR 1910.212(a)(3)(ii), Point of Operation Guarding for All
Machines; As Applied to Hand-Fed Engraving Presses Used in the Engraved
Stationery Manufacturing Industry

1. Purpose

The purpose of this directive is to provide guidance in applying
point of operation guarding requirements relative to hand-fed engraving
presses in the engraved stationery industry, when using the face down method
of printing.

2. Documentation Affected

None.

3. Background

a. Engraving or die stamping presses are not mechanical power
presses. The design, control and operation of these presses are not the same
as mechanical power presses. Although constructed, in part, of closing dies,
the engraving press is a special purpose, continuous operation printing press
with an integrally driven sliding lower die which is automatically
inked.

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OSHA INSTRUCTION STD 1-12.22 JANUARY 2, 1979

b. Guarding the point of operation on hand-fed engraving presses,
where the ink is applied to the underside of the paper, poses a difficult
compliance problem. Barrier guards may cause ink to smear when the paper is
extracted from the press. An awareness barrier is only a partial guard and
does not constitute full compliance with 29 CFR 1910.212(a) (3)(ii). Further
technological difficulties in completely guarding the point of operation have
been uncovered in investigations by insurance companies, New York State
Division of Industrial Services, the Die Stampers and Engravers Union, Local
#30, safety specialists in the National Office, and an independent Safety
Consultant retained to study the problem in 1976. All these studies have
concluded that a point of operation guard which complies with OSHA standards
is not technically feasible, within the current state of the act, for
engraving presses which use the face-down method of printing. Furthermore,
the seriousness of the hazard relative to the point of operation is minimal.
The few recorded accidents that have occurred were primarily during setup,
cleaning, or maintenance.

4. Action

a. In order to provide adequate safety for operators of hand-fed
engraving presses from point of operation hazards, the intent of 29 CFR
1910.212 is satisfied when the following guidelines are followed:

(1) Automatic or semiautomatic feeders shall be used where
feasible

(2) Where automatic feeders are not feasible citations under 29
CFR 1910.212 will not be issued where precautions (a) through (e) are
strictly followed.

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OSHA INSTRUCTION STD 1-12.22 JANUARY 2, 1979

(a) Stock material of sufficient size so that 2 inches or more
of the material being printed projects in front of the closed die is
used.

(b) A finger slot in the counterboard which is 2 inches or more
from the die is used.

(c) A safety training program for press operators and
maintenance personnel to assure safe operating practice and hazard awareness
is instituted.

(d) A sign readily visible to the operator affixed to the press
and warning of the point of operation hazard is in place.

(e) A positive locking device on each manual control to protect
the press operators from unexpected stroking of the ram is installed. The
device shall protect against unintentional engagement of the clutch and shall
be engaged in all circumstances when the employees are required to place
their hands in the point of operation area such as setup, repairs, changing
dies and clearing jams.

b. The engraving industry and the engraving press manufacturer
will continue further research to develop an automatic or semiautomatic
feeder which is capable of processing the small short-run orders, or develop
a positive point of operation safeguarding device. Progress on this research
will be reported annually to the Office of Compliance Programming, Room
N3106.

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OSHA INSTRUCTION STD 1-12.22 JANUARY 2, 1979

5. Effective Date

This directive is effective upon receipt and shall remain in effect
until revised or canceled by standards changes.